Women’s Aid Privacy Notice

Women’s Aid Privacy notice

This Privacy Notice is issued by Women’s Aid (Registered Charity Number 20012045) of 5 Wilton Place, Dublin 2 (“Women’s Aid”, “we”, “our”).

Women’s Aid is the leading national organisation that has been working in Ireland to stop domestic violence against women and children since 1974.  We work to make women and children safe from domestic violence by offering support to women and their families and friends.  During the course of our work, we are required to collect and process personal information from many stakeholders, including our service users, our donors and training attendees.  At Women’s Aid, we are committed to ensuring that personal data collected and processed is treated lawfully and correctly and complies with data protection law, including the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.  The controller (as defined in the GDPR) of your personal data, for all purposes outlined in this Privacy Notice, is Women’s Aid.  Information provided by you is held in strict confidence.  

Women’s Aid is not responsible for the content or privacy practices of any linked sites.

Definitions

• “Personal data” means any information relating to an identified or an identifiable person (‘data subject’); an identifiable person is one who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. 
• “Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion or philosophical beliefs, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
• “Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
• “Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Your Data: What we collect, how we use it and how long we retain it

The information we collect and how we process your data will depend on your relationship with Women’s Aid.

Women’s Aid National Helpline

24 National Freephone Helpline

Our Helpline Support workers are here to listen, and you can contact them by phone or online.  If you would like to talk through some options, they will do that and may also refer you to local domestic violence support services or women’s refuge.  Depending on your needs, the Helpline Support Team will provide a range of information on finance, housing, children, court orders and social welfare. 

If your first language is not English and you would like to speak to us in your native language, we have a Telephone Interpretation Service available in over 170 languages.  This service is free and completely confidential. 

We would like to reassure you that it is your choice if you wish to disclose information regarding the reason for your call or text.

Women’s Aid National Freephone Helpline does not record or retain personal identifiable information.

What information you may wish to disclose during the call:

• Personal details such as your first name;
• If you would like to make an appointment for Court Accompaniment, One to One Service or a third-party support service.  If the Helpline support staff are unable to transfer your call directly to the domestic support service you require, we may ask you for your contact telephone number so we can request the support service to contact you;
• Your health details should you wish to disclose these in the context of domestic abuse, for example if you are pregnant or have a disability;
• Your relationship with the abuser, for example, if the perpetrator is your husband, partner, ex-partner etc.;
• Your experience of the nature and extent of the abuse suffered;
• Any risks that you and your family are experiencing;
• Details of any children you may have (e.g. how many, their ages, gender) and if they suffer abuse at the hands of the perpetrator.  We do not ask you to identify your children by name.  However, if your child(ren) are victims of abuse and you do disclose their name and address, Women’s Aid are under an obligation to make a Child Protection referral to Tusla;  Women’s Aid will also support you to make a referral yourself if you have concerns about your child/ren’s safety.
• Information about anyone else supporting you.

Instant Messaging Support Service

This online service is free, confidential, and secure.  There may be times when you do not have the privacy to phone our National Freephone Helpline or you may simply prefer to contact us online.  This facility is currently available during specific days and times and provides you with an opportunity to contact Helpline Support Team online and instantaneously during this operation period.

We do not ask you for any personal identifiable information and would ask that you do not provide any information via the instant messaging service.    

We will ask your age. If you are under 18 years, our Helpline Support Team will refer you to more suitable services that support minors. 

What information you may wish to disclose during the IMSS conversation:

• Your experience and nature of the abuse you have or are suffering; and
• If the Helpline support team are giving you a referral link for a local domestic support service, we will ask you to confirm the county in which you reside, to ensure we guide you to the appropriate service in your location.

Text service for deaf or hard of hearing women

Our Helpline Support Team will reply to your text message on the mobile number you sent the text from.  

We do not ask you for any personal identifiable information and would ask that you do not provide any information via the text service.

We will ask your age. If you are under 18 years, our Helpline Support Team will refer you to more suitable services that support minors.

What information you may wish to discuss in the text message:

• Your experience and nature of the abuse you have or are suffering
• If the Helpline Support Team are making a referral for a local domestic support service, we will ask you to confirm the county in which you reside to ensure we sent you appropriate information.  If you request us to make a referral to a domestic violence service on your behalf, we will require your first name and a contact phone number/email address.

Power to Change Programme

The Power to Change Programme is a twelve-week programme to help empower survivors of domestic abuse in many ways, including; to help develop personal boundaries and assertiveness skills; to value their self-worth and recognise their own potential; and also to raise awareness of women’s basic rights.

If you participate in the Power to Change Programme, we will collect and process the following personal data relating to you:

• Your name
• Contact details (phone number, email address)
• A brief history of the abuse you suffered to ensure that you are living free from your abuser for at least one year
• How you think the course might benefit you 
• If you have any access requirements, for example, a physical disability.

Your personal details will be used for details of your attendance.  

Personal details provided by you through our application form process will be stored securely and confidentially, and will be shredded 12 months on completion of the course.

How the Helpline will use your data

The Women’s Aid National Freephone Helpline may process personal data relating to you in order to provide you with a listening ear, emotional support and practical information about domestic abuse services available.  The Helpline Support Team may contact a third-party service, on your behalf and with your permission, for example, refuge accommodation, domestic violence support service/court accompaniment, An Gardaí Síochána, or Tusla.

Your experience helps to inform our communication and policy campaigns so that we can increase awareness of domestic abuse and advocate for improved support and services for victims.   

The National Freephone Helpline does not record your data.  However, we do log information for the purpose of collecting statistical information, for example; your relationship with the abuser (current or previous partner, husband, separated), the type of abuse you suffered (physical, sexual, financial, emotional), whether children reside in your household.    

Retention of your personal data by the Helpline

Women’s Aid National Helpline does not record personal data.  We do however, log information for the purposes of compiling statistical reports.  This data is retained for six months. 

If you are attending the Power to Change Programme, we will retain your personal data for a period of 12 months from the conclusion date of the course.

Women’s Aid Direct (Face to Face) Services

One to One Support Services (Outreach and Court Accompaniment) and the High Risk Support Project

If you avail of our One to One Support Services (Outreach and Court Accompaniment) and High Risk Support Project, our staff will review the ‘Information and Confidentiality Notice’ with you during your initial meeting and prior to collecting any personal data relating to you. Due to the nature of this service and the level of distress some women may be in on contact with this service, it may be difficult to provide this information to every woman. Therefore, we encourage you to read our ‘Information and Confidentiality Notice’ here.

If you avail of our One to One Support Services (Outreach and Court Accompaniment) and High Risk Support Project, we will collect information about you and your family, including:

• Personal details about you, for example your name, age, your health.
• Safe ways to contact you.
• Personal details about your children.
• Details about what is happening or has happened.
• Any risks that you or your family are experiencing.
• Information about anyone else supporting you.

Support and Referral Service (Dolphin House)

If you access our Support and Referral Service (“SRS”) and you decide not to avail of our One to One Support Services, we will not collect any personal data relating to you unless we have child safeguarding concerns and are required to make a referral to Tusla, or where we make a referral to another domestic abuse support service on your behalf or to Women’s Aid Legal Clinic or to Women’s Aid Emergency and Legal Fund or  where we advocate on your behalf. However, we do endeavour to inform you of the following verbally at the start of any meeting:

• Confidentiality of the service and limits to confidentiality;
• How we use your information;
• Contact details for Women’s Aid Services Manager.

Due to the nature of this service and the level of distress some women may be in on contact with this service, it may be difficult to provide this information to every woman.  Therefore, we provide a link to the Information and Confidentiality Notice here. The SRS Information and Confidentiality Notice is also laminated on the walls of the waiting area and office of the SRS.  

Women’s Aid Legal Clinic 

The Women’s Aid Legal Clinic is a voluntary and confidential service, staffed by volunteer lawyers whose services are provided free of charge.

If you agree to be referred to our Legal Clinic, you will be asked to complete a referral form with your support worker that asks the following:

• Your Marital / Civil Status (if you are single/married/cohabiting couple/separated/divorced).
• If you are married, details of date and place of marriage and nationality of spouse.
• The date of separation/divorce. 
• Whether you have children and number, age of these children and who they are residing with.
• Any family law court orders previously granted. 
• Reason for attending the Clinic/Outline of family law issue (provide as much information as possible).

This information with your first name only is then passed on with your permission to the law firm that we partner with on this project for the sole purposes of your use of the Law Clinic Services. 

Emergency & Legal Fund require

Where we refer you to our Emergency and Legal Fund we will collect your personal data so that we can administer a grant from the fund. The following personal details will be recorded and issued to our Finance Department so that funds can processed:

• First Name and Surname.
• Postal address if a cheque will be posted. 

You will be asked to provide your explicit consent to the collection and processing of your personal information prior to funds being made available. Due to the nature of our crisis work, this consent is obtained verbally.

How our Services Department will use your data

We collect information about you in order to support you and your family to stay safe.

We use the information you provide us with to inform Women’s Aid on how our services might be improved or developed.

Your experience helps to inform our communications and policy campaigns so that we can increase awareness of domestic abuse and advocate for improved support and services for victims.   

Anonymised information is shared with funders of our service.

Retention of your personal data by our Services Department 

Woman’s Aid Services Department will hold your data for a period of three years.  If after that period of time, you are not in contact with our Services Department, we will delete your records.  All child protection files that have been inactive after three years are also deleted. 

Financial donations to Women’s Aid

If you make a financial donation to Women’s Aid, we will collect and process the following information:

• Name and contact details, including your address, email address and phone number
• Your communication preferences
• Your Bank details 
• The amount you wish to donate
• PPS Number

Your data is collected in one of the following ways:

• Phone
• Post
• Website 
• In person

How The Communications and Fundraising Department will use your data:

The Communications and Fundraising Department will process your personal data for the following reasons:

• To process donations which you make to Women’s Aid.
• To respond to any queries that you have submitted to us via the website.
• To improve and develop our website.
• To provide you with details of our services and training events.
• We collect the PPS number if we receive a tax relief form from the donor to claim from revenue.

When you are making a financial donation to Women’s Aid, your personal contact details are entered into our fundraising database.   Our Communications and Fundraising Department may be in contact with you from time to time to:

• inform you of upcoming campaigns and fundraising activities. 
• tell you how your contribution has improved the lives of women and children suffering domestic abuse.
• to thank you for your support of these endeavours.  

If any time you would like Women’s Aid to cease communication with you, this option is available on our website or you can contact the Communications and Fundraising Department on comms@womensaid.ie

Retention of personal data by the Communications and Fundraising Department

We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Notice, or to comply with our obligations under applicable law and Revenue purposes.

Women’s Aid Training Courses

If you participate in a Women’s Aid training course, you will be asked to complete an application form which will collect the following information:

• Name and contact details, including your address, email address and phone number 
• If you have any access requirements, for example, a physical disability
• The organisation with whom you work
• Your job title

Data may be collected in one of the following ways:

• Email
• Post
• Phone
• Website

How the Training Department will use your data

Your personal details will be registered on a list of training attendees for the course.  This will include your name, organisation and job title.  This list is used to confirm attendance for the training course.

Upon completion of the course, Women’s Aid will issue a certificate listing the course attended, your name and the course date.  

Women’s Aid will also use your information to inform you of upcoming training events.

Retention of personal data by the Training Department

The Training Administrator files a hard copy of the training application form in our files.  These are maintained for a period of 3 years from the date of the training course.

Website Usage Data

Technical details in connection with visits to this website are logged for our statistical purposes.  When you visit our website, the following information is retained about that visit:

• the IP address of your internet connection;
• the type of browser you are using;
• the date and time you accessed our site;
• the pages you accessed on our website and any documents you downloaded;
• the previous website from which you reached us, including any search terms used.

How Women’s Aid use this data:

Women's Aid will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. This information is used to allow us improve the information we are supplying to our users, find out how many people are visiting our sites and for statistical purposes. Some of the above information is used to create summary statistics which allow us to assess the number of visitors to the different sections of our site, discover what information is most and least used, inform us on future design and layout specifications, and help us make our site more user friendly.

Legal basis for Processing Personal Data

The legal bases on which Women’s Aid process your personal data may include one or more of the following legal grounds:

Your consent:
When availing of our ‘face-to-face’ Services, we will rely on your consent to the collection and processing of your personal data.  Due to the crisis nature of our work, it may not be possible for Women’s Aid to obtain consent in certain situations and as such, we may rely on one of the other legal bases, outlined below, for processing your personal data.  

You can withdraw your consent at any time (see ‘Exercising your Data Protection Rights’ below).

To carry out a task that is in the public interest
In our work for justice and social change relating to domestic violence, Women’s Aid are required to report on the service provision to various state organisations and public authorities.  We consider the provision of information to these organisations is in the public interest.  To comply with reporting requirements, Women’s Aid process data about clients and service provision; this data is completely anonymised, pseudonyms are used and identifying details are removed or changed to safeguard our service users.  Where case studies are discussed, pseudonyms are used.

To Protect the Vital Interests of the Individual
In emergency life or death situations, we may process personal data in order to protect the vital interests of an individual.  In a crisis situation, where there is risk of harm, Women’s Aid may be required to share information to prevent such harm.

For Women’s Aid’s legitimate Interests
We may process personal data for the purpose of our legitimate interests in providing our services in a responsible and effective manner and pursuing our social responsibility objectives.  We will not process your personal data for these purposes if to do so would constitute unwarranted interference with your own interests, rights and freedoms.

For compliance with a legal obligation to which Women’s Aid is subject
Under the Children First Act 2015, Women’s Aid is required to report instances of child abuse and neglect. For more information, please see ‘Sharing Your Information With Third Parties’ below.

Legal basis for Processing Special Category Data

Depending on the service that we are providing, Women’s Aid may collect Special Categories of personal data relating to you such as your racial or ethnic origin, nationality and data relating to your health.  

The legal bases on which we process special categories of personal data relating to you are that:

• You have given your explicit consent to the processing of your personal data;
• Where we need to protect the vital interests of you or another;
• The processing is carried out in the course of our legitimate activities as a non-for-profit body;
• The processing is necessary for the provision of health or social care;

Special Category Data may be processed for statistical purposes on the condition it meets conditions set out to safeguard the identification of the Data Subject in addition to adhering to the principle of data minimisation.  Women’s Aid ensure that all personal and special categories of data are anonymised for reporting purposes.  

Processing Criminal Data

To deliver an effective level of service, it is necessary for the organisation to record information deemed relevant to the Woman’s circumstances. We do not record personal information about women or third parties that is not deemed relevant, for example, data relating to criminal convictions such as shoplifting.  An exception, however, is where there are implications for safety of women or staff and where this is the case, we may process personal data relating to criminal convictions and offences in accordance with section 55(1)(b) of the Data Protection Act.

Data Security

To protect the security of all personal data, Women’s Aid have appropriate technical and organisational security measures in place.  These include:

• Encryption, and where appropriate and feasible, pseudonymisation of personal data.
• Women’s Aid ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
• The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
• We have processes for regular testing, assessing and evaluating the effectiveness of both technical and organisational measures for ensuring the security of data processing.
• Personnel who have access to the data are trained to ensure our work is carried out with complete confidentiality.

Sharing your information with Third Parties

Women’s Aid Direct ‘Face-to-Face’ Services:

Generally, the information you share with us about yourself, your family and others and your situation will be treated as confidential by Women’s Aid.  This means that only Women’s Aid staff will have access to this information unless you say otherwise.

Sometimes during our support work with you, you may request us to speak/ we may suggest that we speak, to other agencies outside of Women’s Aid on your behalf (for example the Court Services, An Garda Síochána, Local Housing Authority, the Department of Social Protection). You do not have to give your permission; you can say no.  

Sometimes we are legally required to share information to keep you and your family safe. We do not need your permission to do this but we will always try to discuss this with you as soon as we can, unless it risks safety to do this. The agencies that we usually share information with, in these cases are An Garda Síochána, social services, or other emergency services.

Women’s Aid receives funding for our services.  Women’s Aid has to give reports to our funders to show the number of people we work with and how we are working with them.  This shows numbers of clients; it does not give any names. It is not possible to identify you from the numbers we give to our funders. This includes reports to the benefactors to our Emergency and Legal Fund.

We might make your and other women’s stories anonymous, use pseudonyms and remove/change any identifying information and share this with funders, other agencies and researchers outside the organisation.

We share information in this way to ensure that your or your family’s identity will never be released.

If you become a beneficiary of our Emergency and Legal Fund, then your personal data will be collected and provided to administrators of the fund to administer the fund including our finance department.  

National Helpline

The National Helpline does not record or retain personal data except in the following limited circumstances:

• If you would like to make an appointment for Court Accompaniment, One to One Service or a third-party support service.  If the Helpline support staff are unable to transfer your call directly to the domestic support service you require, we may ask you for your contact telephone number so we can request the support service to contact you.  
• At times Women’s Aid will be required to contact other agencies on your behalf.  This may require us to disclose your personal information to a third party, for example, your first name and phone number if you are seeking refuge accommodation.  In such circumstances, we will always ask for your consent prior to contacting a third party on your behalf and you are entitled to withdraw your consent at any time.
• Women’s Aid have a duty of care and where we are concerned about the safety of your children, we are obliged to report child protection and welfare concerns to Tusla, the Child and Family Agency.  This is not a judgement on any woman but we are merely fulfilling our responsibilities under the Children First Act 2015.

Restrictions to sharing your data: Alleged Known Abuser (AKA)

Women’s Aid do not record AKA names, such as spouses, partners and cohabitees names, on a woman’s files.  

Where there is a concern regarding child safety, the AKA’s name is required for Tusla Child First referrals.  

Women’s Aid acknowledges the general rule that personal information must be provided to anyone in relation to whom Women’s Aid holds Personal Data.  However, due to the sensitive nature of our work, safeguarding a public interest and safety concerns for women and children, Women’s Aid are legally protected under the provisions of Data Protection Act 2018, to restrict access to this data.  

Recipients of Data for Donations and Training Events

We may disclose your personal data to other organisations including third parties who we engage to provide services, such as outsourced service providers, payment processors, IT services providers, professional advisers and auditors.

Transfer of Personal Data outside the European Economic Area (EEA)

In general Women’s Aid do not transfer Personal Data outside the EEA.  However, if we are required to transfer your personal data outside of the EEA, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission.

If you would like to receive further details of the measures that we have taken in this regard, please contact us at servicesmanager@womensaid.ie.

Requirement to Provide Personal Data

You are not under a statutory or contractual obligation to provide us with any personal data. However, if you wish to avail of our services, to attend our training events or to donate to Women’s Aid, we will require certain personal details relating to you.  If you do not provide us with the information required, we may not be in a position to assist you.

Your Data Protection Rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

• Right of Access: you have a right to request a copy of any personal data held by a controller about you.
• Right of Rectification: you have the right to request controllers to rectify inaccurate or incomplete data they hold about you.
• Right to erasure: you have the right to request us to to delete personal data that we hold about you.  This is sometimes referred to as the right to be forgotten.
• Right to restrict or to object to processing: You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
• Data portability: You can request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used, machine-readable format.  

For further detailed information about your data protection rights please visit the website https://www.dataprotection.ie/

If you wish to exercise any of the rights set out above, you can talk to your Support Worker.

Data Access Request Procedure

Due to the nature of Personal Data held by the organisation and in keeping with our mission to safeguard women, Women’s Aid stipulate that data access requests are made in writing.  If you wish to make a data access request you can contact Women’s Aid by emailing servicesmanager@womensaid.ie  or by post to Services Manager, 5 Wilton Place, Dublin 2.  

You will be required to include the following details with your request to ensure Women’s Aid can accurately identify the appropriate records:

• Full name provided when using our services
• Relevant time period(s) you accessed our services
• Any other information which may help us to locate your record
• Contact telephone number

Due to the sensitive nature of our services and the importance of confidentiality, you will be required to verify your identity in person to access the information requested. The following verification documents are required and must be dated within the previous 3 months:

• Proof of identity, such as passport, driving licence or birth certificate
• Proof of address, such as utility bill, bank or credit card statement or revenue tax document.  

Upon receipt of your request, Women’s Aid will contact you to make an appointment for verification purposes within 2 to 3 weeks from the date your request was received.  Within 30 calendar days from the date we verify your identity, Women’s Aid will provide you with the information requested.  However, where requests are complex or numerous, Women’s Aid may extend the period of compliance by a further two months.

Data access requests are free of charge.  However, we will charge a ‘reasonable fee’ when the request is manifestly unfounded or excessive, particularly if it is repetitive.  We may also charge a reasonable fee to comply with requests for further copies of the same information.  This fee is based on the administrative cost of providing the information. 

If you have concerns regarding your data 

If you are concerned with how your data is being collected, processed or stored or if your rights about your data are not adhered to by an organisation, you can contact the Data Protection Commission online or by post as follows:

Online:  https://www.dataprotection.ie/en/contact/how-contact-us

Post: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.

Updates

Women’s Aid may occasionally update our Privacy Notice.  We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.

Privacy Notice for External Parties

This is a general privacy notice for anyone who may be connected to a woman who uses our services.

In general, Women’s Aid only collects the personal data of women who access and use our services.  We may retain information about other individuals from women availing of our services but in these cases we only retain the minimum amount of information necessary for the purposes of complying with a legal obligation that applies to us, for the purposes of defending litigation, or for our legitimate interests in providing services to our users.   This information may include names, addresses, dates of birth, details about family circumstances and other information we may be legally obliged to collect, such as for any referral made to Tusla under child protection obligations.  In general, however, this information is recorded anonymously.  We may transfer personal data to regulatory authorities and law enforcement agencies.  We only store this information for the length of time necessary to comply with our legal obligations or to defend legal claims.

Anyone whose personal data is collected and processed by Women’s Aid has the following rights: the right to access, rectification, objection, deletion, and portability. These rights are only available in certain circumstances and may not be available in some cases.  Women’s Aid takes the confidentiality of its service users very seriously and does not generally discuss any individual case with third parties.  Due to this confidentiality and the nature of Women’s Aid work of working with women experiencing abuse, it is Women's Aid policy, where we are entitled to do so under applicable law, not to grant data protection requests made by other individuals as a result of the possible risk to women who use our services. 

If you proactively contact us regarding the recipient of our service, then we may inform the woman who avails of our service of this contact if it is in the interests of the woman to do so. 

If you have any comments or queries please refer to our Feedback Policy available on our website.

If you are not happy with the way we have used your information or addressed your rights, you have the right to make a complaint to the Irish Data Protection Commission: https://www.dataprotection.ie/.